Motion for Case Management in David G Bertrand et al vs Jessica Berry| Trellis.Law

On May 07, 2019 a Party Statement was filed involving a dispute between Bertrand, David G, Churchill-Johnson, Dorothy, and Berry, Jessica, for Unlimited Defamation (13) in the District Court of Santa Barbara County.

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ELECTRONICALLY FILED
Superior Court of California
County of Santa Barbara
Darrel E. Parker, Executive Officer
1/25/2021 3:29 PM
By: Elizabeth Spann, Deputy

es
2/8/2021
CM-11U
DAVID G. BERTRAND. “WM“
”‘ PLAINTEFFIPETITIONER: 8* al.
190v02429
DE FE NBA NTI‘HESPONDENT: JESSICA BERRY
4. h. Provide a briefstalzementof the case. induding any damages.{ripersonah'njury damages are sanghi, Specr'fy the injury and
damages maimed, fncfudr'ng medics! expenses to date p‘ndﬁcate source and amount}, esﬁmared future medics! expenses.
Insf
if Equitable mffeﬁs sought, describe me new!!! 01' ms! relief.)
earnings I‘D data; and aslr'mated future IDS! earnings.
Defendant made defamatory statements about both PIaintiﬂa. has accused Plaintiff 0f being a "pimp". a
"criminai". and "rapist" among other things with the intent to harass and defame BERTRAND. Defendant was
unjustly enrlched by unreimbursed payments and loans made by Plaintiff BERTRAND.

[:I (.‘fmone space#5needed. check W3 box and aﬁ‘ach a page desfgnated as Attachment 4b.)
Jury or nanjury trial
The party or parties request
requesrr'ng a jury trfaU'
a jury trial|:I anonjun; trial. rrfmom than one party, pmwde the name- of each parry

a.
En.
:I
Trlal date

El
TheIrial has been set for {date}:
oflhe date of the ﬁling afﬁne complaint rff
Na trial dab: has been set. This case will be ready for lriai within 12 monlhs
not expiaa'nJ:

c. Dates on which parties or attorneys will not be available for trial (specify dates and epaJ'n reasons for unevaa'fabim):
- 3.?121'21. 4J15f21. 4IZBF21
2J'3I21, 3!!!!21 - 4:30:91, 6:1:21. ﬁr14#21, WZIZ'I, Tr'f2?:'21
—
750.921

Estlrnated Length of trial
The party Clr parties estimate that the trial will take (check ans):
a. El days (specﬁy number): 4
h. [:I hours {short causes) (specify):

. Trial raprasantaﬁnn {to be answered breach party]
III
The party or parties will be represented at triat
a. Attorney:
by the attorney or listed in the capu'an
Fluent)I [:I by the fuﬂowing.

b. Firm;
9 Address:
:1. Telephone number: 1‘. Fax number:

.
I:
2. E-mail address:
Additional representation is described
Prefemnce
inAttachment B.
9. Party represented:

El COP section 35(8)
Thls case is entitled to preference {spacfﬁi code section): - Plaintiff BERTRAND is 90 years Old-
10.Alternative dispute resolution [ADR]
a. ADR Information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for infnn-nation about the processes availabl'e through the
court and community programs in this case.
(1] For parties represented by counsel: Counsel has El has not provided the ADR information package identiﬁed
in. rule 3.221 to the client and reviewed ADR options with the client.

b,
(2] For self-represented parties:
Party El has :I has not
Referral to judiclal arbitration or civil action mediation
reviewed the ADR informaliun package identiﬁed
(if availabie].
inrule 3 221.

{1] [:1 This matter is sub'acna mandatoryjudiciai arbitration under Code of Civil Procedure section 1141.11 ortu civil action
mediation under ode of Civil Procedure section 1?“?53 because the amount in mntmversy clues nolemeed the
statutory limit.

[2} 1: Civil Procedure sedimn 1141.11.
and agrees to limit recovery to the amount speciﬁed in Code of
Plaintiff eiects lo rater this case to judiciai arbitration

(3‘;|:| This case is exam
mediation under
under rule 3.611 ofthe CaIiﬁJrnia R'ules ofCeur‘tc-r From duil action
tl'rom judicial arbitration
ode ofCivil PrUCEdure section1??5 et seq. (spam? Brampton):

mmtnev-m-NHI CASE MANAGEMENT STATEMENT “9m“
CHI-110
CASE NUMBER.
PLAINTIFFJFETITIONER: DAVID G. BERTRAND. et al.
_ 19CV02429
JEFENDANTfﬁESF'DNDENT: JESSICABERRY

“ID.3.Indicate the ADR process ur processes [hat the party or panies are wiliing to participate in. have agreed to participate in. or
have already participated in (check 31'! that appfy and provide the Specfﬂedinfonnan'on):

The party or parties completing If the party or parties completing this lorm in the £353 haw agreed to
this form am willing tn participate in or have already completed an ADE process or pro-messes.
participate in the Foliowing ADRindicate the slatus of the processes (attach a copy of the parties' ADP
processes {check 3” that appM: stipm'aﬁﬂnj:

Mediation session not yet scheduled

[1] Mediation m Mediation session scheduled for [date]:
EIDIIIIJ

Agreed to complete mediation by [date]:

Mediation completed on {date}:March 161 2020

Settlement conference not yet scheduled

231932021
{2} Settlement
conference
IE EIDBEI
Settlement conference scheduled for [date]:

Agreed to complete settlement conference by {dais}:

Eetﬂement conference completed on {date}:

Neutral evaluatrun not yet scheduled

(3] Neutral evaluaﬁon
El Neutral evafuation scheduled for {data}:
IIIIIIIJD
Agreed to complete neutral evarualion by {dare}:

NEutral evaiualinn mmmeted on (dare):

Judicial amitraﬁun not yet scheduled

{4} Nonbindingjudicial
amitratiun
|:| HEIDI]
Judicial arbitration scheduled for {dare}:

Agreed to complete judicial arbitration by (dare):

Judicial arbitration completed on {date}:

not yet scheduled
Private arbitration

[5}-Binding private
arbitrahun
5 [IUDEI
Private amitration scheduled for {data}:

Agreed to complete private arbitration
by (date):

cumpleled an [date]:
Private- arbitration

ADR session not yet sdieduled

[8: Other [Sp-mm: El ADR session scheduled for(date].-
IIIIIIIIIU
Agreed to complete ADP. session by {dam}:

ADR completed an {dare}:

Jab-1.23!”
“SN-113M?» PLOQSOF5
CASE MANAGEMENT STATEMENT
msenuuaen
cm
" PLAINTIFFJPETITJONEFE: DAViD a BERTRAND,
JESSICA BERRY
91 al.
190v02429
DEFENDANTFRESPONDENT:

11.Insurance
5, [:1 insurance carrier, it any, for party ﬁling this statement {name}:
In. Reservation 0t rights:|:| Yes :5 No
c. E] Covetage issues will 5igniﬁcantly affeci resolution of this case
(Barman-1):

12.Jurisdiction

I:
indicate any maﬁers that may affect the court‘s jurisdiction or processing of this case and describe the staius.

Status:
Bankruptcy |:| Other (SPECI'J‘YJ?

13. Related cases.consolidation. and coordination
a El There are carnpanlum undeﬂying. or related cases.
{1}Name oEcase: DAVID G. BERTRAND v. JESSICA BERRY
{2} Name otoourt: Santa Barbara Superior Court A Anacapa Divislun
{3} Case number: 190V0235T
{4}Sta1us:
[:1 Addrti-Dna! cases are described in Attachmenl 133.
b [:l A motion to |:| consolidate El coordinate will be ﬁled by rname pan‘yJ:

14 Bifurcation
[:I The party or parties intend to ﬁle a motion For an order bifurcating. severing. Dr coordinating the fellowing issues or causes 0*
type of motion. and reasons}:
action {special moving party.

15.Other moiicms
III [we of man's-n. and muss):
The party or parties exped to ﬁle the following motions before u-ial {specify moving party.
P1aintiffs' are preparing to ﬁle an Ex Part3 Appiication for an Order for sanctions against Defendant BERRY for
failure to respond to the Court's Order on written discovery and deposition.
15.
a.
h.
I:
Discovery
The party or parties have completed ail discovery.
The following discovery will be completed by the date speciﬁed {detacﬁba alfanmbﬁled dCUW-‘WJT
Mart 2mm Eat:
Plaintiff Percipient Discovery Per Code
Plaintiff Deposiﬁons Per Code
Plaintiff Record Subpoena to 3rd Parties Per Code

c. The following Gisoovery issues. including issues regarding the discovery- of electronically stored infnn-nalian: are
anlicipatad(Epsom:
Ms. Berry has failed to comply with the Court's prior Order granting Motion to Compel.

I‘M-1 :DﬂRau. JulyI I. 23111
CASE MANAGEMENT STATEMENT “'0" D‘ ‘
CHI-110
“SE “““E‘ER-
PLAINTIFFIFETITIONER- DAVID G. BERTRAND, at al.
_ 190vo242 9
DEFE NDAHTmEsF-DNDENT: JES S ICA BERRY

1T. Economlc litigatlnn
a_ E the amountdemanded
Thus is a limited civil case {i.e.. is $25000 or less} and the economic litigation procedures in Code
of Civil Procedure sections 9088 will apply to Ihis case.
b. |:I This is a Iim'rted civil case and a motion to wimdraw the case from me emnomic “ligation procedures orfar additional
explain speciﬁcaffy why economic Migration procedures Halftime l0 diam-wry 01' Mar
discovery wi1| be mad ﬁ'fchecked.
should nor appw to this Case}:

16. other issues
I:| at me case management
The party or parties requestthat the fuILawing addiljonal matters he considered or determined
conference (speciﬁc:

19. Meet and confer
a. m The party or parties have met and conﬁned with all parties on all subjects required by rule 3.?24 ofthe California Rules
axpfaa'nj;
of Court (If not.

h. After meeting and conferring the California Rules of Court. the parties agree on the following
as required by rule 3.?24
(specify):

20. Total number of pages attached (Harm:

Iam mmplelely familiar with this case and will be fully prEpared tu discuss the status of {liwwerjuI and aﬂernative dispute resolution.
as wen as other issues raised by this statement, and will possess the authvarityI to enter into stipulations on these issues at the time of
the case management conference. including the written authority of the party- where required.

Date: January 25.

Marl-c
21121

T. Cofﬁn. Attorney for Plaintiffs
HYPE {JR PRINT NAME]
D

D
Iu ..
.
M[SIGNFITUHE OF PARTY CR ATTORNEY:

mar: (:R Paw? NMHE] [SIGNATURE CF PN‘TY GR ATrUHNEYJ

E Additional signatures are attached.

CHM-W" M WWI CASE MANAGEMENT STATEMENT
“PM“
PROOF OF SERVICE

STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA

I am cmploycd in the County of Santa Barbara, State of California. 1 am over the age of 18

years: and not a party In [his actinn, My business address is 21 F..Carrillo Slreel, Suite 240, Santa
Barbara, California 93101. On Janualy 25., 2021, I served the foregoing documents described as
PLAINTIFFS’ CASE MANAGEMENT STATEMENT, on the interested parties in this action:

Address Party
Jessica Ben";
aomum
JESSICA BERRY, in pro per.
RU. Box 541
Santa Ynez, CA 93460

10 Jessica Berry
PO. Box 432
I1 iSolvang, CA 9346-1
=
E: {ceskatcnrdic-ﬁigmail.com
12 .E: Berrfessic-aﬂﬁmﬁ maiLcum

16
ti BY L‘. S.
Service.
MAIL:
I
This document was served by United StaTcs mail through the US Postal
enclosed the document In a sealed envefope or package addmssed
al, the address(es) above and piaced the envelope(s) tor collection and mailing.
lo the persun(s)
following our
nrdmary business practices [ am rcadiiy familiar with this ﬁrm 3 practice of collecting and
1? processing correspondence for mailing. On the same day that correspondence is phlced For
collection and mailing, it is deposited in the ordinary course 01‘ business with the United
States Postal Service at Santa Barbara Calilbmia? in a sealed envelope with postage fully
paid.
19
V IA EMAIL: scrwd the documents above on all parties via electronic mail, to the
20 R addresses as
[
listed on the attached service list following In} employrgr 5 business practlcc for
coElection and processing ufconeswndence Such electmnic transmission was reported as
21 complete and without error on this date.

22 E {State} I declare under penally ol'perjury under the laws of tho State of Califomia that the
ibregning is true and correct.
23

24 Executed on January 25, 2021, at Santa Barbara, California

’25

27
W
Scott A. 15151::
Q W;
23

6
PlﬂiﬁTlFFS' CASE, MANAGEMLN'I‘ STATEMENT

Case Info

Judge

Sterne, Colleen K Track Judge’s New Case

Case No.

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Document Filed Date

January 25, 2021

Case Filing Date

May 07, 2019

County

Parties

Berry, Jessica Defendant
Bertrand, David G Plaintiff
Churchill-Johnson, Dorothy Plaintiff
Coffin, Mark T Attorney for the Plaintiff
Pro Se Attorney for the Defendant
Colleen Sterne Attorney
David Allard Attorney
Colleen Keeley Attorney
Jan Kaestner Attorneys for Defendants
Robert Hutchins Attorney
Michael Holtzman Attorney
Scott Jaske Attorneys for Plaintiffs
Mark Thompson Attorneys for Plaintiffs
Ashley Reese Attorney
Jay Valentine Attorney
Brian Hoffman Attorney
Wabel Moussly Attorney

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Party Statement: David G Bertrand et al vs Jessica Berry

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